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Lotus — Privacy Policy

Effective 1 September 2026 · v1.2 — plain-English on purpose

This Privacy Policy explains how Evergreen Studio Pty Ltd (ABN 74 700 261 276, ACN 700 261 276) (“we”, “us”, “our”), a company registered in Victoria, Australia, collects, uses, stores and protects your personal information when you use the Lotus mobile application (the “App”) and our website (the “Site”, together the “Service”).

Lotus is a self-help app that supports people who want to reduce or stop gambling. Because of what the App is for, some of the information you choose to put into it is sensitive information under the Privacy Act 1988 (Cth), including health information about your gambling recovery and wellbeing. We have designed Lotus so that we collect as little as reasonably necessary, we never sell your information, and your recovery data is accessible only through your account and to us and our service providers where reasonably necessary to operate, secure or support the Service as described in this policy.

1. The short version

• We never connect to your bank. All money tracking in Lotus is manual — numbers you type in yourself. Lotus has no ability to see your accounts, balances or transactions, and never will by design.
• We never sell your information and we do not show advertising or share your information with advertisers or data brokers.
• Your recovery data is yours. Check-ins, moods, journal entries, spend and savings logs are stored in your account, protected by the safeguards described in section 9, and used only to provide, secure and support the App as described in this policy.
• Analytics are optional and do not include the content of your recovery data, but analytics events are pseudonymous rather than anonymous because they are linked to your account's internal user ID. If (and only if) you switch on “Share usage data”, we record which features are used — never amounts, never moods, never journal text.
• You can request deletion from inside the App at any time, subject to the limited retention described in section 8.
• Lotus is for adults (18+).

2. Information we collect

2.1 Account information

• Email address and password. Used to create and sign in to your account. Passwords are hashed by our authentication provider; we never see or store your password in readable form.
• Sign in with Apple. If you choose “Continue with Apple” instead of a password, Apple confirms your identity to us and may give us your name and an email address, depending on the information and sharing options associated with your Apple account. If you use Apple's “Hide My Email” option, we only receive a private relay address instead of your personal email address. We do not receive your Apple password. We receive only the information Apple makes available to us through the Sign in with Apple service, as described above.

2.2 Profile and settings

• Your country/region (used to show the correct local support services and currency — you choose it, we do not track your location).
• Your estimated monthly gambling baseline (a number you enter during setup, used for the App's opportunity-cost calculations).
• Your consent choices and when you made them (agreeing to the terms, confirming you are 18 or older, and the optional analytics and email-updates toggles). We keep an append-only record of the consent or choice, its date and time, the applicable policy or terms version, and any later withdrawal or change so we can evidence your choices.
• A referral code (randomly generated for your account) and referral activity if you use the invite feature.

2.3 Recovery data you choose to record

These exist only if you enter them, and are the heart of what the App does for you:

• Daily check-ins, including an optional mood.
• Gambling spend logs (amount and date).
• Savings logs (amount, date, and which goal they count toward).
• Goals (name and target amount).
• Journal entries and “reasons” (free-text notes you write).
• Urges you logged as ridden out.
• Progress through guided programs (which step of which program you are on).

We treat all of the above as sensitive information because, taken together, it relates to your health and wellbeing. We collect this sensitive information only with your express consent, requested separately before you first enter it, and use or disclose it only as reasonably necessary to provide, secure and support the App, or as otherwise required or authorised by law; entering recovery data after giving that express consent supplies the information, but does not by itself replace the consent request. We never use it for advertising, profiling or any purpose you would not expect.

2.4 Feedback

• If you send feedback from inside the App, we receive the message you write plus your platform (iOS/Android) and App version. Feedback is write-only from the App and is accessible only to authorised personnel and service providers who need it to respond, operate or secure the Service; you can request its deletion by deleting your data, subject to section 8.

2.5 Information stored only on your device

• Small preferences like your chosen theme and dark-mode setting are stored on your device itself and are not sent to us.
• Optional reminders (morning encouragement, evening check-in nudge) are off by default and, if you turn them on, are scheduled entirely by your phone. No reminder information is sent to us or anyone else, and their wording never mentions gambling or money.

2.6 Website waitlist

• If you join the waitlist on our Site, Formspree collects your email address on our behalf and discloses it to us, which may involve overseas processing as described in section 6. We use it only to tell you about Lotus's availability, and you can unsubscribe or ask us to delete it at any time, subject to any retention required or authorised by law.

3. What we deliberately do not collect

• No bank or financial account access — ever. Lotus does not connect to banks, cards or financial data aggregators. This is a permanent design decision, not a missing feature.
• No precise location. Your region is a setting you pick, not something we detect.
• No contacts, photos, microphone or other device data.
• No advertising identifiers, and no third-party advertising or marketing SDKs.

4. How we use your information

• To provide the App: storing your entries so your lotus, goals, insights and program progress work and stay in sync when you reinstall or change devices.
• To operate the referral program (matching a redeemed code to the account that shared it).
• To respond when you contact us or send feedback.
• To send you occasional email updates about Lotus — only if you turned on the email-updates toggle (it is off by default). You can turn it off at any time in the App.
• To understand feature usage through optional pseudonymous analytics and aggregate reporting (see section 5).
• To keep the Service secure (for example, rate-limiting abusive requests).

We do not use your information for automated decision-making that affects you, we do not build advertising profiles, and we do not sell or rent personal information to anyone.

5. Analytics (optional, off unless you opt in)

During setup (and at any time in the App's settings) you can choose whether to turn on “Share usage data”. If you leave it off, no PostHog analytics events are sent. If you turn it on, we send a small set of named events to PostHog, our analytics provider, hosted in the European Union:

• Events like: app opened, check-in completed, saving logged, spend logged, program step completed, referral redeemed, Plus trial started, lotus rebirthed, feedback submitted.
• What is never sent: money amounts, journal or feedback text, moods, goal names, or anything you wrote. Events carry only the event name and basic context such as App version.
• Events are linked to your account's internal user ID (a random string), not your email address, so they are pseudonymous personal information rather than anonymous information.
• Opens of the calm kit and crisis pathway are deliberately not tracked at all.

6. Where your information is stored and overseas disclosure

• Main database and authentication: hosted with Supabase in Sydney, Australia. Supabase is a US-headquartered provider, so limited support or operational access may occur from overseas, including the US.
• Analytics (only if opted in): PostHog processes pseudonymous analytics in the European Union, hosted in Germany. This means opt-in analytics events (described in section 5) are disclosed overseas to the EU.
• Subscriptions: RevenueCat, a US-based subscription-management provider, records whether your account has an active Lotus Plus subscription. This means your account's internal user ID and your subscription status are disclosed overseas to the US. We do not intentionally send RevenueCat your name, email, payment card details or recovery data described in section 2.3.
• Waitlist form (Site only): Formspree, a US-based form provider, processes the email address and any associated technical information collected when you submit the form in the United States.

7. Who we share information with

We disclose personal information to the following service providers only as reasonably necessary for the described purpose, subject to contractual privacy, security and use restrictions appropriate to the information disclosed:

• Supabase — database hosting and authentication (Sydney, Australia).
• PostHog — optional analytics (EU), only if you opt in.
• Formspree — website waitlist form (US), only if you use it.
• Apple App Store / Google Play — if you subscribe to Lotus Plus, the relevant store processes the purchase, payment, receipt and subscription administration under its own privacy terms. We never see your card or payment details.
• RevenueCat — subscription management (US). It sits between the app store and Lotus and tells us only whether your subscription is active, linked to your account’s internal user ID. If you sign in with Apple, Apple also acts as your identity provider (section 2.1).

Beyond that, we disclose personal information only where required or authorised by law, including where we reasonably believe disclosure is necessary to lessen or prevent a serious threat to life, health or safety, and we limit any disclosure to what is legally permitted and reasonably necessary. We will never voluntarily hand your recovery data to gambling companies, advertisers, or data brokers, and we do not respond to commercial requests for user data.

8. How long we keep information, and how to delete it

• We keep your information only for as long as reasonably necessary for the purposes described in this policy, including while your account is active, and then delete or de-identify it unless retention is required or authorised by law.
• Delete from inside the App: Settings → delete my data initiates permanent deletion of your check-ins, spend and savings logs, goals, journal entries, reasons, urge logs, program progress, feedback, lotus history and profile from active systems, subject to limited retention in backups and records required or authorised by law.
• Account login record: deleting your data from inside the App also initiates removal of the email/login record, subject to the limited retention described in this section; residual copies may remain temporarily in backups (kept for up to seven days) or where retention is required or authorised by law. If deletion does not complete in the App, contact us at the address below and we will investigate promptly, complete the request within 30 days where reasonably practicable, and tell you if we need more time or must retain particular information by law.
• Subscriptions are separate: a Lotus Plus subscription is billed by the app store (Apple or Google), not by us, so deleting your data does not cancel it. You can cancel any time in your device’s app-store subscription settings, and the App reminds you of this before you delete.
• Consent and choice records, including the applicable version, date and time, age confirmation, express consent to sensitive-information collection, analytics and email choices, and any withdrawal, may be retained after account deletion only for as long as reasonably necessary to establish or defend legal claims or as otherwise required or authorised by law, with access restricted accordingly.

9. How we protect your information

• We use encryption in transit (HTTPS/TLS) and reasonable technical and organisational safeguards appropriate to the sensitivity of the information we hold.
• Database access controls are designed to prevent one user from accessing another user's rows, while permitting access by authorised personnel and service providers only where reasonably necessary to operate, secure, support or comply with law.
• Passwords are hashed by our authentication provider and are never visible to us.
• Rate limits and database-level checks protect against abuse.
• We never hold bank credentials or payment card details, because the App never collects them.

No system is perfectly secure, but if we suspect an eligible data breach we will promptly contain and assess it and, where the Privacy Act requires, notify affected individuals and the Office of the Australian Information Commissioner as soon as practicable, including the recommended response steps.

10. Your rights

10.1 Everyone

• Access the information the App holds about you (most of it is visible in the App itself; contact us for a copy of the rest).
• Ask us to correct personal information that is inaccurate, out of date, incomplete, irrelevant or misleading, and to associate a statement with it if we refuse correction.
• Delete your information (see section 8).
• Withdraw consent for analytics or email updates at any time in the App's settings, and withdraw consent to future collection of recovery data by stopping further entries or contacting us, without affecting processing that occurred before withdrawal.

10.2 Australia

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. If you have a privacy complaint, contact us using the details below; we will acknowledge it, investigate it and respond within 30 days, or tell you if we reasonably need more time. If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au.

10.3 United Kingdom and European Union

If UK GDPR or EU GDPR applies to you, our legal bases are: consent (for the recovery data you enter, analytics, and email updates) and legitimate interests (for security and service operation). You have rights of access, rectification, erasure, restriction, portability and objection, and the right to withdraw consent at any time. You may complain to the UK Information Commissioner's Office (ico.org.uk) or your local supervisory authority.

10.4 United States (including California)

We do not sell or share personal information as those terms are defined in the California Consumer Privacy Act, and we have not done so. California residents have the right to know, delete, and correct personal information, and the right to non-discrimination for exercising those rights. Exercise them via the App or by contacting us.

10.5 Canada

We handle personal information consistent with PIPEDA. You may access and correct your information and withdraw consent as described above, and may contact the Office of the Privacy Commissioner of Canada with concerns.

10.6 New Zealand

We handle personal information consistent with the Privacy Act 2020 (NZ). You may access and correct your information, and may complain to the Office of the Privacy Commissioner (privacy.org.nz).

11. Children

Lotus is for people aged 18 and over. Account creation requires confirming you are 18 or older, and we do not knowingly collect personal information from anyone under 18. If you believe a person under 18 has created an account, contact us and we will delete it.

12. Changes to this policy

If we change this policy, we will update the date at the top and, for material changes, give reasonable advance notice in the App or by email where practicable before the change takes effect. If a change would materially expand how we collect, use or disclose sensitive information, we will seek fresh express consent before applying that change to the sensitive information.

13. Contact us

Evergreen Studio Pty Ltd (ABN 74 700 261 276)

Email: hello@evergreenstudios.net.au

We aim to respond to privacy requests and complaints within 30 days and will verify your identity before giving access to, correcting or deleting personal information where reasonably necessary to protect it.